2025 Sanctions Year in Review: Trends, Enforcement Signals and the Road Ahead
Castellum.AI presents the fifth edition of Sanctions Year in Review, an annual analysis of global sanctions activity, trends and enforcement priorities. Paired with actionable insights and recommendations, the report provides a roadmap for compliance leaders to identify emerging risk exposure and potential gaps in sanctions controls.
Key Sanctions Trends in 2025
US sanctions recalibration: Under the Trump administration, OFAC shifted its sanctions priorities to focus on Iran, narcotics trafficking, organized crime networks and fraud. Absent from US priorities in 2025? Russia.
Broader sanctions activity across jurisdictions: In 2025, the EU, UK, Canada, Switzerland and the UN expanded sanctions activity, reflecting more assertive, independent use of sanctions tools and increasing cross-jurisdictional compliance complexity for global firms.
Focus on enablement networks: Sanctions increasingly targeted logistics, financing, cyber and facilitation networks, reflecting a shift toward operational disruption. For example, 57% of sanctions against Iran in 2025 targeted parties located in countries like China, the UAE, Marshall Islands and India.
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Total Active Sanctions by Major Global Authorities
In 2025, the global sanctions landscape shifted away from US dominance. The US added 2,223 new sanctions, a 30% decrease from the 3,165 added in 2024 and the slowest growth since 2022. By contrast, sanctions activity outside the US accelerated. Canada (17%), Switzerland (13%), France (12%) and the EU (11%) all recorded steady increases.
Implications for Compliance Teams
Banks, fintechs and crypto firms with global footprints must navigate hundreds of new US, EU, UN, Canadian and Swiss designations, sometimes with overlapping but non-identical scope and other times—completely different.
For example, The US imposed sanctions on International Criminal Court judges, including citizens of Canada and France, that have not been adopted by other authorities. Likewise, only the UK imposed sanctions on former Guatemalan president Alejandro Giammattei.
Institutions relying primarily on OFAC-based controls face growing exposure to aligning their screening policy with divergent regulatory regimes, especially where EU or other international sanctions regimes trigger downstream asset freezes, correspondent banking restrictions or additional exposure through local 50% rule regulations.
OFAC Shifts Focus to Iran, Narcotics and Crime
Under Trump, OFAC concentrated on Iran, narcotics and transnational criminal ecosystems, signaling renewed reliance on coercive pressure tools.
Focus centered on Iran: Iran dominated US sanctions activity with 856 new designations. This was reinforced by “maximum pressure” style actions targeting Iran-linked shipping and oil networks, aimed at severing funding to Iran's weapons program and armed forces.
Cartels and narcotics traffickers reframed as national security threats: The Trump administration also placed a heavy emphasis on transnational crime (199), terrorism (181) and narcotics (150), reflecting a sanctions strategy aimed at disrupting terrorist and transnational criminal networks and their facilitators, not just state actors. Moreover, the classification of major international cartels under terrorist organizations expanded sanctionable conduct beyond narcotics trafficking.
Russia deprioritized: In the final 20 days of Biden’s term in January, OFAC issued 10 times more Russia-related sanctions (584) than the Trump administration imposed across all of 2025 (56) — underscoring how markedly sanctions priorities changed under the new administration.
Implication for Compliance Teams
In 2026, compliance teams should prepare for secondary sanctions risk tied to correspondent banking, trade finance and cross-border payment exposure across high-risk trade corridors and financial hubs, including China, the UAE, Turkey and India. Institutions operating in Latin American corridors should expect heightened scrutiny under both terrorism finance and transnational crime programs, requiring real-time sanctions screening and enhanced transaction monitoring controls.
Crypto and Digital Assets Sanctions
Crypto embedded in sanctions evasion: Digital assets are now a persistent feature of state-linked sanctions evasion, cybercrime and transnational fraud networks. Moreover, sanctioned activity expanded beyond Bitcoin and Ethereum into Tron, Monero and other opaque crypto rails.
OFAC Enforcement Actions in 2025
Upstream accountability: Enforcement shifted into capital formation and enabling services. Venture capital, private equity and intermediary structures are being targeted as high-risk segments that help sanctioned parties retain access to the international financial system.
Control effectiveness at scale: OFAC penalized failures in sanctions compliance systems, not just intentional wrongdoing. The Interactive Brokers case illustrates how regulators evaluate testing rigor, validation and governance of compliance technology to ensure that systems operate effectively and as expected.
Cooperation directly affected penalty size: Reporting failures and subpoena non-compliance appeared directly in enforcement narratives and materially influenced penalty outcomes.
Go Beyond the Highlights
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